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by benterix 36 days ago
People who say there is no free speech in Europe have never lived in an authoritarian country.
1 comments

But its mainly Americans saying it here on HN.
I haven't seen it here much (apart from proper rednecky comments equating carrying gun everywhere with some actual personal freedoms but those are rare).

But most US population ain't HN, at all. Most don't travel, get their opinion on the world from CNN or Fox news with corresponding results and thus have rather primitive view on rest of the world (sorry, that is true, one needs to travel a bit to understand world).

You don't travel when you are crushed by debt and rising costs from all sides, do you.

This is not only an American problem. Most people in most countries get their view of the rest of the world from mass media and social media. In some places people think particular groups they meet or read about (e.g. tourists or workers) are typical of the country they come from.

Travel produces different distortions. A lot of British people think the rest of the world is a lot better than it is because they visit places on holiday: they visit nice places and have good experiences. I have known some to get into messes when they actually try to live somewhere else.

I think you can turn this into a proper, nuanced position by contrasting how the US typically values protection of free speech higher than protection from libel/slander/defamation.

Just consider prominent recent examples, like the german student protester that was investigated by police and had his sign confiscated (it just said "Merz (current cancellor) suck balls"). This seems ridiculous and draconian by US standards.

I work at a German university. We had pro Palestinian protests 4 times a year for a while now and there has not been a single arrest. In fact there has not been a single police officer present over the past 4 years that would have even carried out an arrest. The only reason for a police officer to typically enter university grounds are noise complaints.

The case you quoted did happen, but it is one of a few crazy outliers. In the meantime you have literal university police bashing in on protesters, border police looking into peoples smart phones and policing their social media, students being expelled for pro palestinian positions, ...

I'm not saying that you can't protest in Germany, just that european free speech/defamation protection tends to lean a bit more against defamation.

You call that a crazy outlier, but under the previous administration some retiree had police knock on his door and confiscate his tablet (!) because he posted a meme calling a member of the green party an "idiot" (Schwachkopf).

Meanwhile, all the counterexamples that people bring up here are strictly tied to the Trump administration.

Like the standard of denying people entry to the country based on their social media posts? Or deporting them for the same? Or the standard of tear-gassing a peaceful "No Kings" crowd of U.S. citizens, full of children?

Or literally investigating all protestors, at scale? https://www.nytimes.com/2026/03/19/us/politics/justice-dept-...

Those, to me, are mainly authoritarian tendencies of the current administration.

That is a different argument: The Trump administration is not really shifting the defamation vs. free speech tradeoff in the US (you could argue that it does, in the opposite direction, by slandering political opponents with insulting nicknames like "crooked Hillary" or "sleepy Joe").

> This seems ridiculous and draconian by US standards.

The DHS is sending subpoenas to google over mildly critical online posts. [0] By your own standards, that must be ridiculous and draconian too, yes?

[0] https://www.cbc.ca/news/world/us-dhs-aclu-lawsuit-canadian-j...

Yes. But there is still a significant difference between some agency snooping around when it shouldn't and police physically taking your things, and exactly that happened both under the current and the previous german administration, just for milquetoasty insults ("idiot" and "<cancellor> suck balls", respectively). Both cases are great examples of the Streisand effect btw, there is even a short film about the first one.
Not quite the same thing since it was a school official rather than police, but we had something similar in the US. Right down to confiscation of a juvenille sign.

https://en.wikipedia.org/wiki/Morse_v._Frederick

That still seems somewhat defensible to me; there has to be line somewhere (you probably would want to suspend students advertising crack cocaine use during school, right?). And "I got suspended during school despite doing something that was not literally illegal" is a weak position in the first place IMO.

But police knocking on your door and confiscating your device because you called some politician an "idiot" by posting an online meme seems almost unthinkable in the US, when even the president himself is slinging insults like that at political opponents all the time.

My point is not that there is clear black/white line and the US have free speech and Europe doesn't, just that the free speech/defamation tradeoff is slightly different.

Important that it was not "during school". The student in question had not even been to school that day. He just showed up at an event that was near the school, that school officials were also at.

But your overall point - that not every population defines free speech the same way - is accurate. I think the difference here is just a bit less than sometimes implied.

Maybe, but it was during school hours. Every court ruling on this decided that it counted as "school speech", which makes sense to me, similarly to how a school should be able to suspend if you misbehave on a school trip IMO.